Regulatory watch
Massachusetts EVV requirements and claim edits
- Home Health Agency Bulletin 94 (May 2025)
- Adult Foster Care Bulletin 33 (May 2025)
- HCBS Waiver Provider Bulletin 24 (July 2025)
- The checkpoint document, titled Electronic Visit Verification Compliance Measures (last updated May 30, 2025)
- The edits and reason codes guide (undated)
- Managed Care Entity Bulletin 137 (September 2025); the link goes to MassHealth’s provider bulletin list
- The May 2024 overview deck; the link goes to MassHealth’s EVV topic page
- The Hard Edits Cheat Sheet (file name “MA EVV Hard Edits Cheat Sheet - 7.2026.Update”)
Three phases, the last one scheduled
MassHealth staged EVV in three steps: register, hit a rising share of clean visits, then let the billing system refuse claims with no matching visit. The first two have dates. The third is scheduled for September 2026, and no document read here says it began.
| Step | Status | What it covers | Source |
|---|---|---|---|
| EVV in use | Since September 2024. | Home health, group adult foster care and the ABI and MFP waivers. | Bulletin 94 |
| Phase 1: registration | Within 30 days of each bulletin. May 2025 for home health and foster care; July 2025 for the waivers. | Sign up with Sandata, directly or through a registered alternate system. | Bulletin 24 |
| Phase 2: visit checkpoints | 30, then 40, then 50 percent, per the checkpoint document. The checkpoint document’s 50 percent level runs from April 1, 2026 until claim edits begin. | Home health and group adult foster care: the share of all visits with no manual entry or edit. | Checkpoint document |
| Soft edits | In place as of October 2025. A mismatch posts EOB 784 on the remittance advice. | Fee-for-service home health, group adult foster care, ABI and MFP waivers. | Edits guide |
| Phase 3: hard edits | Scheduled for September 2026. Floor: no earlier than July 2026. No document read says the go-live happened. | A claim pays only when a matching verified visit is in the aggregator. | Bulletin 33; cheat sheet |
| Health plans | Same three phases, no dates. Bulletin 137, September 2025. | Including ACPPs, Primary Care ACOs, MCOs, One Care, Senior Care Options, PACE and the behavioral health vendor. | Bulletin 137 |
Status as of October 11, 2026, the day these copies were downloaded and read.
Two dates bear on hard edits. The three provider bulletins set a floor: MassHealth would add the edits no earlier than July 2026. The Hard Edits Cheat Sheet then schedules the hard-edit go-live for September 2026. None of the eight documents reports that the go-live happened, and the edits guide, in the copy read on October 11, 2026, still tells agencies to prepare for when hard edits arrive.
MassHealth in its own words
- On phase 3, Home Health Agency Bulletin 94 in the copy read October 11, 2026: “No earlier than July 2026, MassHealth will implement edits into its billing system to allow claims to pay only when a corresponding visit is correctly entered into the EVV system.”
- On what counts toward a checkpoint, the same bulletin: auto-approved visits are “visits submitted in the EVV system that have not been corrected manually by the provider.”
- On the hard edits, the edits guide read October 11, 2026: they “will result in claims denial if the submitted claims do not have matching EVV visit records.”
- On the model, the May 2024 overview deck: providers “can use their own EVV System and send their EVV-related data to the EVV Data Aggregator, or they can utilize the EVV System that the State will provide.”
Sandata on both sides
In Massachusetts one company does two jobs. Sandata Technologies supplies the state’s own EVV system for agency-based services and also runs the aggregator that receives visits from the state system and from registered alternate systems. An agency that prefers its own software registers it as an alternate EVV system; its visits still go to the Sandata aggregator, carrying the same six data elements. The May 2024 overview deck names a different vendor, Tempus Unlimited, for self-directed personal care attendant EVV.
GPS in the MassHealth papers
The six data elements include where the service was delivered. Beyond that, none of the eight documents makes GPS a condition. The one mention is in the May 2024 overview deck, which lists, among the features of Sandata’s phone app, that it records GPS when a visit starts and ends. That is a property of one app, not a line in a bulletin.
Visits fixed by hand
Massachusetts measures agencies on visits nobody had to touch. A visit captured at clock-in and clock-out counts as auto-verified; one that was keyed in or edited afterwards counts as manually verified. The checkpoints only credit the first kind, so an agency that repairs many visits can sit below the bar even when every visit is complete. For claims, the edits guide treats both kinds as able to match, provided the visit is in a verified status before the claim arrives.
What follows a missed checkpoint
The bulletins describe two steps: a notice of noncompliance on a first miss, then a formal notice of sanction on a second, with termination from the MassHealth provider network possible beyond that. They cite two MassHealth regulations, 130 CMR 450.238 and 450.239, which this page did not read and does not characterise. For health plans, Bulletin 137 points to corrective action or intermediate sanctions under each plan’s contract.
Known, and not yet known
Known from the documents: the September 2024 start, the registration windows, the three checkpoint levels and their periods, soft edits from October 2025, the July 2026 floor for hard edits and their September 2026 schedule, and the Sandata arrangement. The edits guide’s table already marks an unmatched EVV line “No Pay”, with a note that this may not reflect how the whole claim is decided; it says no more than that about payment under soft edits. Not known from the documents: whether the scheduled September 2026 go-live took place, whether the checkpoint levels have moved since May 30, 2025, dates for the health-plan phases, and how the cited regulations apply. Earlier search results on these points were never treated as facts here.
LockProof beside MassHealth EVV
The aggregator answers MassHealth’s question: is there a verified visit behind this claim. A LockProof photo answers a narrower one: what the caregiver’s camera recorded at the visit, held so that editing it afterwards would show. How the two sit side by side is covered in photo records kept next to an EVV system, and the capture itself gets its own walkthrough.
Scope of this page
Every source is a copy the founder downloaded from mass.gov on October 11, 2026. Six links go to the download addresses recorded for those copies; the links for Bulletin 137 and the overview deck go to MassHealth listing pages instead. Our network cannot open mass.gov, so no link was opened from here; if one has moved, the bulletin numbers will turn the bulletins up, and Bulletins 94 and 24 point readers to MassHealth’s “Electronic Visit Verification for Agency-based Providers” page for the checkpoint figures. The edits guide carries no date of its own. Agency contracts, waivers and plan terms were not reviewed; that is for counsel. Other states are on the state EVV overview, including Minnesota’s rewritten statute.
Common questions
Where does GPS fit in Massachusetts EVV?
Not as a written rule. None of the eight MassHealth documents read for this page makes GPS a condition. The edits guide and the May 2024 overview deck list six data elements, the place of service among them, and the deck notes that the state’s Sandata phone app records GPS when a visit starts and ends. That is a description of one vendor’s app, and an agency on its own registered system is not told to use it.
When do MassHealth EVV claim edits start?
MassHealth’s Hard Edits Cheat Sheet schedules the hard-edit go-live for September 2026. Home Health Agency Bulletin 94, Adult Foster Care Bulletin 33 and Waiver Bulletin 24 had set a floor of no earlier than July 2026, after which a claim pays only when a matching visit sits in the EVV system. None of the eight documents read for this page says the go-live has happened, and the edits guide still speaks of hard edits as coming.
What share of visits has to go through without manual changes?
MassHealth’s checkpoint document, last updated May 30, 2025, sets 30 percent for April 1 to June 30, 2025, 40 percent for July 1, 2025 to March 31, 2026, and 50 percent from April 1, 2026 until claim edits begin. It counts visits that were neither keyed in nor corrected by the agency, over all visits rather than claims, for home health and group adult foster care, and it says the figures can change.
Can a Massachusetts agency run its own EVV system?
Yes, if the system is registered as an alternate EVV system and sends its visits to the state’s aggregator. MassHealth calls this an open model: Sandata supplies both the state system and the aggregator, and Home Health Agency Bulletin 94 lets agencies use either. Self-directed personal care attendant visits run through a different vendor, Tempus Unlimited, according to the May 2024 overview deck.
Does LockProof count for MassHealth EVV?
Not at all. MassHealth has no registration for LockProof as an alternate EVV system, and LockProof is not an EVV system of any kind; nothing it holds reaches Sandata’s aggregator or any claim edit. An agency may keep it as a separate photo record, for the family member or payer who later asks the agency what happened on a given visit.
Is this page a substitute for legal advice?
No. Eight MassHealth documents are summarised here, each downloaded and read on October 11, 2026. Which services, plans or checkpoints reach a particular agency, and how to answer a notice of noncompliance, are matters for counsel or for MassHealth itself.